Whether, where in respect of an assessment year, there is income under a head, the loss, if any, under any other head for that assessment year should first be set-off against it before the carried forward losses under the former head can be set-off against such income
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Inter-head set-off priority requires current-year losses to be adjusted before applying carried-forward losses. Inter-head set-off under section 71 takes priority: where an assessment year shows income under one head and a loss under another, the contemporaneous loss must be set off against that income before carried forward losses under the income-bearing head are applied. This sequence is subject to Chapter VI exceptions that prohibit inter-head adjustments for certain losses, and departmental return formats have been aligned to reflect this method of computation.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Inter-head set-off priority requires current-year losses to be adjusted before applying carried-forward losses.
Inter-head set-off under section 71 takes priority: where an assessment year shows income under one head and a loss under another, the contemporaneous loss must be set off against that income before carried forward losses under the income-bearing head are applied. This sequence is subject to Chapter VI exceptions that prohibit inter-head adjustments for certain losses, and departmental return formats have been aligned to reflect this method of computation.
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